WWALS Watershed Coalition advocates for conservation and stewardship of the Withlacoochee, Willacoochee, Alapaha, Little, and Suwannee River watersheds in south Georgia and north Florida through education, awareness, environmental monitoring, and citizen activities.

Re: Docket ID No. EPA-HQ-OW-2018-0149,
Revised Definition of Waters of United States

To Whom it May Concern:

WWALS Watershed Coalition, Inc. (WWALS), also known as Suwannee Riverkeeper, submits the following comments on the United States Environmental Protection Agency (“EPA”) and Department of Defense, Department of the Army, Corps of Engineers (“Corps”) proposed rule entitled “Revised Definition of Waters of United States,” 84 Federal Register 4154-01 (February 14, 2019) (hereinafter “Proposed Rule”).

In addition to supporting the comments of Waterkeeper Alliance and the Southern Environmental Law Center (SELC), WWALS adds these comments on groundwater.

The Proposed Rule’s categorical exclusion of groundwater makes no sense here above the Floridan Aquifer where surface water and groundwater constantly interchange, and pollutants travelling through groundwater are a frequent source of health, environmental, and economic problems.

Thanks to
Jim Tatum of OSFR for spotting this op-ed in the
Lake City Reporter yesterday
by WWALS member and Practicing Geologist Dennis J. Price of Hamilton County, Florida about
Nutrien (PCS) mining phosphate and water in Hamilton County and
likely planning to expand to Columbia County.

Much has been written in the last year about Sam Oosterhoudt’s
mitigation bank. I was involved in permitting the bank through the Army
Corps (ACOE) and The Florida Department of Environmental Regulation. It
took about 5 years to get all the permits. Now, 9 years after work began
on the project, the phosphate company (then PCS now Nutrien) petitioned
the state to shut down the mitigation bank.

I do not know for sure, but, Nutrien may tell you that during the
recent sale of PCS and the review of mineral interests owned, they
discovered that the mitigation bank had snuck in there and set up shop
over their minerals. This probably has some truth to it but I think
there is a much more involved reason.

In Hamilton County, Nurtrien/PCS is planning to run out of phosphate
to mine in about 10 years, give or take a few years either way. I do not
believe they are planning on shutting the doors and leaving. Occidental
Chemical Company started mining in Hamilton County Continue reading →

Common question: isn’t Hotchkiss closed?
Answer: the old
Hotchkiss Landing
in Lowndes County is closed, private, and
don’t go there!
But
Hotchkiss Road Landing
in Lanier County is open as always, do go there to get to the Alapaha River.
And there’s a new park at US 84, with a Naylor Boat Ramp being built
by Lowndes County, as urged by WWALS.

Previously there was some discussion of using a different name for
Hotchkiss Road Landing in the Alapaha River Water Trail,
but then nobody would know what we were referring to, since that’s what it’s
always been called, down at the end of Hotchkiss Road off of US 84.

Update 2018-12-30: The new organization WATERKEEPERS Florida, as one of its first acts, on December 19, 2018, signed the Resolution Against Phosphate Mines in Florida, thus committing all thirteen of its member organizations.

WHEREAS, Waterkeeper Alliance Members are obligated and dedicated to protect the water
resources, citizens’ interests, and related benefits in their
jurisdictions; and

WHEREAS, phosphate mines have been shown to threaten and cause actual harm to these
resources, interest, and related benefits; and

WHEREAS, there are several phosphate mine projects in various stages of permitting in local,
state, and federal agencies including county and city governments,
Water Management Districts (WMDs),
Florida Department of Environmental Protection (FDEP),
U.S. Army Corps of Engineers (USACE); and

WHEREAS, there seems to be no public list of current phosphate mines and related facitlities,
which include at least

Why should anyone downstream care about an obscure creek north of Valdosta?
Because it runs
past sinkholes that leak into the Floridan Aquifer,
into the Withlacoochee River, then into the Suwannee River,
then into the Gulf of Mexico,
going by all seven of the downstream Florida counties that passed
resolutions asking the state of Florida to do something about Valdosta wastewater,
not to mention neighborhoods and wetlands closer to the
recent Cherry Creek Lift Station sewage leak,
which was at least smaller than previous spills.

Sabal Trail did not notify state or local officials about their “odorant” leak
at the Dunnellon Compressor Station site,
and
Sabal Trail’s
response to WWALS
failed to mention local people called the same stink in to 911 two days
in a row.
FDEP
said there’s no need so long as Sabal Trail follows various permits,
but gave no indication of who is checking to see if Sabal Trail does that.
Apparently we the people have to keep doing what the state and federal
agencies still aren’t doing: watch Sabal Trail like a hawk.

Google map of locations of Dunnellon High School and Sabal Trail Dunnellon Compressor Station.
You can see most of the 100-foot Sabal Trail right of way.

Today
Sabal Trail Inc. is pounding a 36-inch pipe under the
Withlacoochee River to force-feed us Marcellus Shale fracked gas.
The powers who own decision-makers have made sure laws and
regulations designed to protect the planet don’t apply to
themselves. Twentieth century mindset — 21st century reality
notwithstanding, they’ll offer a few hundred temporary jobs, conduct
corporate social responsibility PR programs before moving on to
other ventures, enabled by government agencies and politicians eager
to board the fracked-gas crony capitalist bullet train, while the
people, our waters and health are classified acceptable risks.

Mission accomplished while taking land through eminent domain with
an unknown (by the public) quantity for export — unsurprising
since there are Continue reading →